What taxes do export agency companies need to pay on behalf? How to avoid tax risks in entrusted agency exports?

I.Export RepresentationWhat taxes does the company need to pay on behalf of clients?

According to the current Provisional Regulations of the Peoples Republic of China on Value-Added Tax andExport Drawbackpolicies, formal export agency companies mainly deal with three types of taxes:

• VAT treatment
  • Buyout agency: The agency company declares output tax based on the full amount of goods and applies for tax rebates with input invoices
  • Commission-based agency: Only pays 6% VAT on the service commission portion
• Corporate Income Tax: Calculated at 25% of total annual profit, agency fee income is included in taxable income
• Customs duties and import link taxes: InvolveEntrepot TradeWhen required, legally declare and pay customs duties, consumption taxes, etc.

II. Can entrusted agency exports enjoy tax rebate policies?

The latest 2025 policy clarifies that tax rebates can still be applied for through agency exports, but three conditions must be met:

• Export enterprises must complete(Note: Specific processing items are hidden here, agency companies need to provide operation guidelines)
• Goods must actually leave the country and obtainExport Clearanceform
• The agency company must have general taxpayer qualification

Special reminder: The 2024 General Administration of Customs updated customs declaration form completion specifications require(Note: Agency companies need to provide specific clauses for that year), which directly affects the legality of tax rebate documents.

III. Differences in tax treatment under different agency models

• Buyout agency (export in own name)

  Tax characteristics:

  • The agency company is the legal seller
  • Must issue VAT special invoices to clients
  • Tax rebate funds are received by the agency companys account
• Entrusted agency (dual-header customs declaration)

  Operation points:

  • Customs declaration forms must show both manufacturer and agency company information
  • The tax rebate entity remains the actual export enterprise
  • Agency fees should be separately accounted to avoid mixing with operating income

IV.foreign tradeThree major tax risks enterprises must pay attention to

• Document management risks

  2025 tax bureau investigation cases in multiple regions show: 46% of export tax rebate disputes originate from(Note: Agency companies need to supplement specific risk point cases here)

• Fund return monitoring

  The latest SAFE supervision system can automatically compare(Note: Agency companies need to update specific supervision measures here)

• Pricing of related party transactions

  Cross-border service fee payments must comply with the arms length principle to avoid being identified as profit transfers

V. How to verify an agency companys tax compliance?

It is recommended that clients require agency companies to provide:

• Tax credit rating certificates for the past three years (must reach level B or above)
• Copies of Customs AEO certification certificates
• Export tax rebate account custodian bank qualification documents
• Most recent quarterly VAT declaration forms (desensitized processing)

(Note: This article is based on current tax laws and regulations. Specific operations should follow the interpretation of the competent tax authorities. It is recommended that foreign trade enterprises sign Tax Compliance Commitment Letters with agency companies to clarify rights and obligations of both parties.)